What has not changed
The ATO's published market valuation for tax purposes guidance remains the framework. The principles are unchanged: valuations must reflect market value (per IVS 104), the methodology must be appropriate, the evidence must be documented, the assumptions must be reasonable, and the report should be prepared by an appropriately qualified and independent person. There is still no register of approved valuers. There is still no template that guarantees acceptance. "ATO-approved" is still not a real thing.
What is shifting in practice
Three practical shifts are worth understanding. First, the ATO has continued to focus on small business CGT concession claims as a review area — particularly where eligibility is marginal or where the $6m net asset value test is close to the threshold. Second, related-party transactions, particularly intra-family share and unit transfers, receive close scrutiny when the value applied appears to favour the tax outcome over a defensible market position. Third, the rise of online valuation tools and AI-generated valuations has increased ATO interest in whether the methodology and evidence behind a stated value is documented at a defensible standard.
What this means for business owners
If you are commissioning a tax-purpose valuation in 2026, three things matter more than they did a few years ago. Documented methodology: the report must clearly explain which methodology was applied and why. Evidence trail: the working papers behind the report must be available if the file is queried. Independence and supportability: the report must be prepared by a provider who can defend the conclusion under review — not just produce a number.
What this means for accountants and advisers
Advisers carrying client valuation work in their files are increasingly exposed where the underlying valuation is thin. A one-page calculator output or an unsupported value-from-instinct in an accountant's file may not survive a query. A defensible valuation report — independent, methodology-tested, evidence-documented, senior-signed — sits in the file and stands up. The cost of a defensible report is typically a fraction of the cost of an unsupportable position being challenged.
What we are seeing in practice
Across the engagements we run, the common theme is that the substantive work pays for itself. The Defensible Valuation File tier, with three methodologies tested, full evidence pack and senior signatory, is increasingly the right choice for any matter where the underlying transaction value exceeds $2–3m or where small business CGT concessions are claimed. The Valuation Range & Scenario Review engagement is appropriate where the matter is complex, contested, or where the adviser wants the structured range analysis to inform the engagement structure.
A note on what we do not do
We do not predict ATO behaviour. We do not promise acceptance. We do not produce target values. What we do is prepare valuation positions the evidence supports, with the methodology and reasoning documented to the standard the ATO reviews against. Where review occurs, the file is designed to hold up. Where it does not occur, the file sits in the accountant's working papers as a piece of substantive professional work.